2023-cv-61767

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16914942, filed by FEDERATION OF THE SWISS WATCH INDUSTRY FH.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the FH Trademarks

Clerks Notice of Judge Assignment to Judge Raag Singhal. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Alicia O. Valle is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

Complaint

Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement by FEDERATION OF THE SWISS WATCH INDUSTRY FH

Plaintiff's MOTION to Seal per Local Rule 5.4 by FEDERATION OF THE SWISS WATCH INDUSTRY FH.

Text of Proposed Order

NOTICE OF COURT PRACTICE Unless otherwise specified by the Court, every motion, legal memorandum, brief, and otherwise shall: be double-spaced, in justified alignment, in 12-point font, using either Times New Roman or Arial typeface. This Notice does not supplant the requirements and provisions of Local Rule 7.1(c). The Court cautions parties against excessive use of footnotes. Multiple Plaintiffs or Defendants shall file joint motions (and responses to motions) with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions (and responses). Parties are encouraged to seek extensions of time in a timely fashion. "A motion for extension of time is not self-executing; no motion is, unless expressly provided for by the applicable rule. Yet, by filing these motions on or near the last day, and then sitting idle pending the Court's disposition of the motion, parties essentially grant their own motion. The Court will not condone this." Compere v. Nusret Miami, LLC, 2020 WL 2844888, at *2 (S.D. Fla. May 7, 2020) (internal citations omitted). Exhibits to pleadings and motions shall be docketed in accordance with the Courts CM/ECF procedures, Rule 3L.(2): (2) Describing an Attachment to a Docket Entry A party filing an attachment to a document shall select one of the prescribed attachment categories from the drop-down menu (e.g., affidavit, transcript), provide an alphabetical or numerical designation (e.g., Exhibit A, Exhibit 1), and descriptively name each attachment (e.g., Exhibit 1 - Affidavit of Boo Radley) in a manner that enables the Court to easily locate and distinguish attachments. (Emphasis added.) Local Rule 16.4, Local Rules for the United States District Court for the Southern District of Florida, requires that a Notice of Settlement "shall be filed and served jointly by counsel for all parties to the settlement." A unilateral notice of settlement will not stay pre-trial deadlines or hearings. Failure to comply with any of these procedures may result in the imposition of appropriate sanctions. Signed by Judge Raag Singhal on 9/15/2023. (am00)

PAPERLESS ORDER TO FILE CERTIFICATE OF INTERESTED PERSONS Within SEVEN (7) DAYS of entry of an appearance, each party, including governmental parties, must file certificates of interested parties and corporate disclosure statements that contain a complete list of persons, associated persons, firms, partnerships, or corporations that have a financial interest in the outcome of this case, including subsidiaries, conglomerates, affiliates, parent corporations, and other identifiable legal entities related to a party. The parties shall not include Judge Singhal or the paired magistrate judges unless they have an interest in the litigation. Throughout the pendency of the action, the parties are under a continuing obligation to amend, correct, and update the certificates. Signed by Judge Raag Singhal on 9/15/2023. (am00)

ORDER TO FILE UNDER SEAL granting [5] Motion to File Under Seal. Signed by Judge Raag Singhal on 9/18/2023. See attached document for full details.

Order

Plaintiff's MOTION to Unseal by FEDERATION OF THE SWISS WATCH INDUSTRY FH.

Text of Proposed Order

Clerk's Notice to Filer re 15 Miscellaneous Relief. Filer Selected the Wrong Motion Relief(s); ERROR - The Filer selected the wrong motion relief(s) when docketing the motion. The correction was made by the Clerk. It is not necessary to refile this document but future motions filed must include applicable reliefs.

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by FEDERATION OF THE SWISS WATCH INDUSTRY FH.

Exhibit 1 to Amended Complaint Certificates of Registration for the Swiss Trade

NOTICE of Filing Proposed Summons(es) by FEDERATION OF THE SWISS WATCH INDUSTRY FH

Summon(s)

Plaintiff's NOTICE by FEDERATION OF THE SWISS WATCH INDUSTRY FH re [1] Complaint, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by FEDERATION OF THE SWISS WATCH INDUSTRY FH re [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [2] Clerks Notice of Judge Assignment, [10] Order on Motion to Seal, [3] Form AO 120/121, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [8] Notice of Court Practice/to Appear/Other, [1] Complaint, [9] Order, upon Defendants via website posting

ORDER granting 15 Motion to Unseal Case. The Clerk of Court is directed to unseal all docket entries in this case and return those portions of the Court file to the public records. Signed by Judge Raag Singhal on 9/27/2023. See attached document for full details.

Clerk's NOTICE of Compliance re 21 Order on Motion to Unseal Case. All Docket Entries Unsealed.

Summons Issued as to THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A.

Plaintiff's NOTICE by FEDERATION OF THE SWISS WATCH INDUSTRY FH of E-Mail Inquiry Received from Defendant Number 2

Exhibit 1 to the Notice of E-mail Inquiry

PAPERLESS Minute Entry and MINUTE ORDER for proceedings held before Judge Raag Singhal: Motion Hearing held on 9/28/2023 re 6 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets. Total time in court: 0 hour(s) : 15 minutes. Attorney Appearance(s): Virgilio Gigante. Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov. Signed by Judge Raag Singhal on 9/28/2023 (am00)

ORDER Granting [6] Application for Entry of Preliminary Injunction. Signed by Judge Raag Singhal on 9/29/2023. See attached document for full details.

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [17] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by FEDERATION OF THE SWISS WATCH INDUSTRY FH. bestreplicasever.ru served on 12/1/2023, response/answer due 12/22/2023; bestrepwatch.store served on 12/1/2023, response/answer due 12/22/2023; bigocean.shop served on 12/1/2023, response/answer due 12/22/2023; breitlingwataches.shop served on 12/1/2023, response/answer due 12/22/2023; buywatches.store served on 12/1/2023, response/answer due 12/22/2023; crwcchz.top served on 12/1/2023, response/answer due 12/22/2023; cuuwatchesworld.com served on 12/1/2023, response/answer due 12/22/2023; dentency.com served on 12/1/2023, response/answer due 12/22/2023; fas4style.com served on 12/1/2023, response/answer due 12/22/2023; henryme.shop served on 12/1/2023, response/answer due 12/22/2023; kcxmdendaw.top served on 12/1/2023, response/answer due 12/22/2023; legowatches.us served on 12/1/2023, response/answer due 12/22/2023; naokkio.com served on 12/1/2023, response/answer due 12/22/2023; octime.shop served on 12/1/2023, response/answer due 12/22/2023; onluxurytime.com served on 12/1/2023, response/answer due 12/22/2023; patekphilippe.top served on 12/1/2023, response/answer due 12/22/2023; perfectwatch.cn served on 12/1/2023, response/answer due 12/22/2023; prodowatch.com served on 12/1/2023, response/answer due 12/22/2023; replicahause.eu served on 12/1/2023, response/answer due 12/22/2023; swissluxurysh.top served on 12/1/2023, response/answer due 12/22/2023; watches.is served on 12/1/2023, response/answer due 12/22/2023; watcheskeep.com served on 12/1/2023, response/answer due 12/22/2023; watchesuk.sr served on 12/1/2023, response/answer due 12/22/2023; zoeluxury.com served on 12/1/2023, response/answer due 12/22/2023.

Affidavit of Service

Affidavit of Service

Plaintiff's MOTION for Clerk's Entry of Default as to The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, bestreplicasever.ru, bestrepwatch.store, bigocean.shop, breitlingwataches.shop, buywatches.store, crwcchz.top, cuuwatchesworld.com, dentency.com, fas4style.com, henryme.shop, kcxmdendaw.top, legowatches.us, naokkio.com, octime.shop, onluxurytime.com, patekphilippe.top, perfectwatch.cn, prodowatch.com, replicahause.eu, swissluxurysh.top, watches.is, watcheskeep.com, watchesuk.sr, zoeluxury.com by FEDERATION OF THE SWISS WATCH INDUSTRY FH.

Exhibit Declaration of Stephen M. Gaffigan in Support of Request for Clerk'

Text of Proposed Order

CLERK'S DEFAULT ENTRY: Granting [28] Plaintiff's MOTION for Clerk's Entry of Default as to The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, bestreplicasever.ru, bestrepwatch.store, bigocean.shop, breitlingwataches.shop, buywatch filed by FEDERATION OF THE SWISS WATCH INDUSTRY FH. Signed by DEPUTY CLERK on 1/3/2024. See attached document for full details.

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Vijay Pattisapu. Filing Fee $ 200.00 Receipt # AFLSDC-17193149 by cuuwatchesworld.com. Attorney Charles Arthur Acevedo added to party cuuwatchesworld.com(pty:dft). Responses due by 1/22/2024

Exhibit 1: Sworn Declaration of Vijay Pattisapu

Text of Proposed Order : Order Granting Motion to Appear Pro Hac Vice, Consent t

NOTICE of Attorney Appearance by Charles Arthur Acevedo on behalf of cuuwatchesworld.com

STRICKEN - CLERK'S NOTICE - re 30 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Vijay Pattisapu. Local counsel/Movant, Carlos A. Acevedo must file/sign documents under the name listed on the SDFL Roll of Attorneys, Charles Arthur Acevedo. See www.flsd.uscourts.gov/name-changes. It is not necessary to refile this motion. (pt) Modified text on 1/8/2024 to mark entry as stricken

Clerk's Notice to Filer re 31 Notice of Attorney Appearance, 30 MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Vijay Pattisapu. Filing Fee $ 200.00 Receipt # AFLSDC-17193149. Login/Signature Block Violation; CORRECTIVE ACTION REQUIRED WITHIN 3 DAYS - The name of attorney e-filing this document via their CM/ECF login does not match the name of attorney on the signature block of the document. The name used for login must match typed name on signature block of the document. This filing is a violation of Section 3J(1) of CM/ECF Admin Procedures and LR 5.1(b). Filer must File a Notice of Striking, then refile document pursuant to CM/ECF Admin Procedures and Local Rules.

Corrected MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Vijay Pattisapu. Filing Fee $ 200.00 Amended/Corrected Motion to Appear Pro Hac Vice Filed - Filing Fees Previously Paid. See [30] Motion to Appear Pro Hac Vice, by cuuwatchesworld.com. Responses due by 1/22/2024

Exhibit 1: Sworn Declaration of Vijay Pattisapu

Text of Proposed Order Granting Motion to Appear Pro Hac Vice, Consent to Design

NOTICE of Attorney Appearance by Charles Arthur Acevedo on behalf of cuuwatchesworld.com

NOTICE of Striking by cuuwatchesworld.com

Attorney Vijay Pattisapu representing cuuwatchesworld.com (Defendant) Activated.

PAPERLESS ORDER denying as moot 30 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Vijay Pattisapu in light of Attorney's Corrected Motion to Appear Pro Hac Vice (DE 34). Signed by Judge Raag Singhal on 1/8/2024. (am00)

PAPERLESS ORDER denying without prejudice 34 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Vijay Pattisapu. Local counsel/movant is listed as Carlos Acevedo who does not appear on the Roll of Attorneys of this Court's Bar. Notice of Termination delivered by US Mail to Vijay Pattisapu. Signed by Judge Raag Singhal on 1/8/2024. (am00)

Corrected MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Vijay Pattisapu. Filing Fee $ 200.00 Amended/Corrected Motion to Appear Pro Hac Vice Filed - Filing Fees Previously Paid. See [34] Motion to Appear Pro Hac Vice, [30] Motion to Appear Pro Hac Vice, by cuuwatchesworld.com. Responses due by 1/22/2024

Exhibit 1: Sworn Declaration of Vijay Pattisapu

Text of Proposed Order : Order Granting Motion to Appear Pro Hac Vice, Consent t

PAPERLESS ORDER granting 39 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for Attorney Vijay Pattisapu. Signed by Judge Raag Singhal on 1/9/2024. (am00)

ANSWER and Affirmative Defenses to Amended Complaint by cuuwatchesworld.com.

Plaintiff's NOTICE Notice Of Identification of Additional Aliases for Defendant Numbers 10, 18, and 20 and Additional Payment Accounts Used by Defendant Numbers 5, 6, 7, 9, 10, 12, 14, 17, 18, 20, 22, and 23 by FEDERATION OF THE SWISS WATCH INDUSTRY FH

Declaration of Virgilio Gigante in Support Thereof

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

Plaintiff's MOTION for Default Judgment and Memorandum of Law In Support Thereof by FEDERATION OF THE SWISS WATCH INDUSTRY FH.

Text of Proposed Order Granting Motion for Final Default Judgment

Text of Proposed Order Final Judgment and Permanent Injunction

Declaration of Virgilio Gigante in Support Thereof

Exhibit 1 to the Declaration of Virgilio Gigante

ORDER GRANTING MOTION FOR FINAL DEFAULT JUDGMENT, granting [43] Motion for Default Judgment. Signed by Judge Raag Singhal on 2/23/2024. See attached document for full details.

NOTICE of Settlement as to Defendant Number 7 by FEDERATION OF THE SWISS WATCH INDUSTRY FH

ORDER ADMINISTRATIVELY CLOSING CASE.Dismissing Case / Closing Case. Signed by Judge Raag Singhal on 3/19/2024. See attached document for full details.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

Order

Agreed MOTION for Preliminary Injunction as to Defendant Number 7 by FEDERATION OF THE SWISS WATCH INDUSTRY FH.

Text of Proposed Order

NOTICE of Striking [48] Agreed MOTION for Preliminary Injunction as to Defendant Number 7 filed by FEDERATION OF THE SWISS WATCH INDUSTRY FH by FEDERATION OF THE SWISS WATCH INDUSTRY FH

Agreed MOTION for Permanent Injunction as to Defendant Number 7 by FEDERATION OF THE SWISS WATCH INDUSTRY FH.

Text of Proposed Order

PAPERLESS ORDER striking 48 Agreed Motion for Entry of a Permanent Injunction as to Defendant Number 7 in light of Plaintiff's Notice of Striking Docket Entry 48 (DE 49). Signed by Judge Raag Singhal on 4/9/2024. (lp00)

AGREED PERMANENT INJUNCTION AS TO DEFENDANT NUMBER 7, granting [50] Motion for Permanent Injunction. Signed by Judge Raag Singhal on 4/9/2024. See attached document for full details.

Joint MOTION for Extension of Time to File Stipulation of Dismissal as to Defendant Number 7 by FEDERATION OF THE SWISS WATCH INDUSTRY FH. Responses due by 4/29/2024.

Text of Proposed Order

PAPERLESS ORDER granting 53 Joint Motion for an Extension of Time to File Stipulation of Dismissal as to Defendant Number 7. The parties shall file their stipulation for dismissal as to Defendant Number 7 on or by 4/29/2024. Signed by Judge Raag Singhal on 4/16/2024. (lp00)

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION. JUDGMENT in favor of FEDERATION OF THE SWISS WATCH INDUSTRY FH against The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A. Signed by Judge Raag Singhal on 4/16/2024. See attached document for full details.

STIPULATION of Dismissal by FEDERATION OF THE SWISS WATCH INDUSTRY FH

ORDER OF DISMISSAL. Dismissing Case / (Without Prejudice) Signed by Judge Raag Singhal on 4/29/2024. See attached document for full details.